On 30 November 2012, SAI Global announced a commercial arrangement with SafetyCulture for the sale of generic Safe Work Method Statements (SWMS), particularly for high-risk industries. This has caused something of a stir with some Australian safety professionals who claim that this runs contrary to good safety practice. The controversy of SWMS in Australia is a hot topic and one that is unlikely to be resolved soon, as it goes to the heart of some of the safety red-tape objections from the business sector.

“SAI Global Limited (ASX: SAI) has signed a distribution agreement with SafetyCulture Pty Ltd one of Australia’s leading providers of Occupational, Health and Safety information and materials, to publish and sell their “Safe Work Method Statements”.

These Safe Work Method Statements, developed by SafetyCulture, are templates documenting procedures and methods for safely executing common tasks and operations on construction sites.

These templates cover a wide range of potentially dangerous tasks and activities which:

Save construction companies time and effort drafting various OH&S procedures for different applications.

Are available in Word format and can be easily tailored to meet the requirements for specific construction sites.

Are based on industry expertise and latest OH&S best-practice for high-risk construction work.”

SafetyAtWorkBlog has written previously about the commercial situation and strategy of SAI Global and its relationship with Standards Australia. SAI Global has always been a commercial organisation that has marketed the work undertaken by Standards Australia. This has never sat well with many safety professionals as some, including SafetyAtWorkBlog, have argued that any Standards referenced in workplace safety legislation should be free or at a reduced cost due to their role in preventing incidents and harm.
It has been argued that if the Australian Government wants to reduce safety costs to small business, it should consider providing safety management standards at no, or little, cost.

What has raised the ire of many safety professionals is that the source of the generic SWMS has come from another commercial body, SafetyCulture. Describing any company as “leading”, as in the above quote, only ever describes market position and never product quality. At one point Enron was a leading energy company and Lehman Brothers was a leading merchant bank and Madoff was a leading investment adviser. “Leading” is a red flag for more analysis on a company or organisation.

SafetyCulture provides a timeline of the company’s development on its website but no information about the technical OHS resources and expertise used for its product development. The company has certainly made some inroads into the online safety app sector but many of the safety professionals’ concerns could be assuaged with more background on expertise and SWMS development.

SAI Global has only ever claimed these products to be templates which should be tailored to the needs of construction workers, a point that SAI Global’s Simon Berglund is at pains to stress in some OHS discussion forums. There is a growing trend to step away from the generic SWMS to the more relevant Job Safety Analyses or a simplified SWMS that is handwritten by the work crew on the day prior to commencing work in an area or a shift. In this way some construction companies are reinforcing the need to have SWMS live up to their intentions and not be an administrative task that someone in an office wrote weeks or months earlier.

“Safe Work Method Statements are, basically, a set of instructions for how to complete a prescribed task as safely as can reasonably be expected. The current Work Health and Safety Act 2011 only requires such documents for eighteen specific high-risk construction activities. [SAI Global offers many more than eighteen] The current mythology, however, which has proved enormously difficult to dislodge, is that all risks must be managed, and documented, and have a corresponding SWMS that can be produced when an inspector calls or if the employer ends up in court.

This mythology has been perpetuated by some in the industry for varying reasons, few if any of which are valid. Auditors, safety consultants and inexperienced or less qualified safety managers have all been culprits in perpetuating this myth, despite attempts by the local industry to lay most of the blame at the feet of the Federal Safety Commission.

Some of the Territory’s most senior safety managers are still yet to be convinced, despite protestations by WorkSafe ACT to the contrary, that they are not required to have a SWMS in place for workers walking over uneven ground on a construction site, or walking up stairs on a multi-level site. This is despite the fact that most people mastered such activities in early childhood.

Perhaps what the perceived issues surrounding SWMS actually represent is the inability of the local industry to see beyond the most basic of responses to demands for safer worksites. Whether this is due to an undue focus on profit margins, with safety seen as a mere ‘embuggerance’, or whether the responsibility for this lies more broadly among all of the stakeholders, it nonetheless has become an obstacle to seeing the bigger picture…….

For this specific issue, the answer is to comprehensively debunk the SWMS myth. To do this alone, however, and not shift the focus from paperwork to work practices, from systems-based controls to behavioural and cognitive controls, will not achieve the safety outcomes we must all expect from the construction industry.” (page 44)

Further to the mention of the Federal Safety Commission (FSC) above, the FSC states in its factsheet on SWMS that:

“As SWMS form the primary source of documented OHS guidance for workers, it is essential that they are involved in its development and clearly understand the material. Whilst some of the core information contained within a SWMS may be relevant across multiple projects, much of the information should relate to the specific situation on each project. As such, site specific SWMS should be developed for all projects.” (emphasis added)

The concerns of safety professionals comes largely from their experience that safety templates often become a default process that is diverted to become an SEP (Someone Else’s Problem) or simply a piece of paper that is never looked at and one that everybody hopes is never asked about.

An earlier incarnation of SafetyCulture, Wades Business Solutions, provided the following context to SWMS that is missing from the SAI Global site:

“Main Reasons Why Staff Do Not Adhere To Safe Work Method Statements

Safe work method statements are implemented without involvement with staff.

Different policies or work procedures don’t seem to be well-communicated.

Work procedures and improvements aren’t thoroughly enforced.

Employees openly accept a policy and independently neglect it.

Personnel do not think the principles affect them.”

Templates without context may be the basis for many of the safety professionals’ concerns.

Briggs’ and McCabe’s quote above displays their frustration with how the myth of the SWMS has grown out of control and is seen as a joke by some, an inconvenience by most and a useful safety tool by few. The SWMS system and regulatory expectations need a reboot across Australia and particularly in the high risk construction sector where SWMS could be of the greatest practical use. Issuing templates is not helping in this need for revision but SAI Global has long been a commercial leopard that seems to have no intention of changing its spots and needs to develop more commercial products to rebuild its profitability. Sadly it seems to be a short-sighted leopard.

18 comments

This SWMS approach is likely to cause problems in relation to the consult and communication requirements under the Model OHS approach which are aimed at ensuring a robust discussion with workers on Hazards and Controls in the workplace, remember the learning rules;i hear – loose 60% i see – loose 45% i hear see and do loose – 20% as i recall . John kirwan

In my eyes this is profiteering from safety. Further, it is at the expense of people missing out on the opportunity to understand what the SWMS is all about and how to safely plan a work activity. I agree with you John, consultation, communication and; particularly, understanding is threatened here. One perul is managers/workers using generic documents they’ve not developed, have little understand of or acceptance of the documents initiatives. Good point Kevin.

Not so much myth as one might think having seen numerous common law cases pursued for negligence for among other things not being shown correct method or process to walk over uneven ground apart from a few pissed off inspectors at times queryin the SWI / SWMS for such activity. time the regualtors got their houses in order at the same time and yes time SAI stopped using standards as aadamn big profit machine. You can get free standards in US or Canada – it would be a huge move here especially for teh little businesses to be able to access freeeeeeeee!!!!!

I would like to reply to your article to answer some of the questions you have raised.

Firstly, I agree with your core message in relation to SWMS, some employers are relying on them as a way to cover their obligations without proper implementation. They are also being used as a way to train employees across a range of activities in addition to the core high risk activities they were originally intended for. Better methods of training could be utilised and we are also working on developing more engaging methods of engages workers on a daily basis.

I created SafetyCulture after personally investigating and managing around 2500 workplace accidents as a workers compensation investigator and manager of a team of 25 field Investigators. I felt that with better training and greater safety awareness, many of the matters I investigated could have been avoided.

I wanted to make safety more affordable, so all employers could implement safe systems of work.

We started out with basic OHS Policies dealing with issues such as drugs and alcohol in the workplace. This was not a new concept, safety professionals had been providing these services for years, and yet, a large number of employers were not employing the services of a professional or training their staff to work safely.

In 2004, when I started the company, there was little choice for employers in regards to OHS resources that were available to them. In my family oil distribution business, OHS Consultants would come in annually wanting thousands of dollars to generate documentation that was very similar to what they created for their last client. They would also have little interest in the utilisation of those documents once they had been paid for them.

Other small business operators I spoke to, had spent between $12,000 and $27,000 on documentation, which was collecting dust on their shelves and not being implemented. This was easy money for some consultants who were motivated by money rather than safety. I wanted to start a company that made safety more affordable.

As we created a safe work method statement for a client, there was some repetition when working with another client with the same needs. We didn’t feel it was necessary to charge the entire cost associated with creating a document from scratch so we began to make it available to other employers at a subsidised rate and then also offered them as generic SWMS.

We required all clients to agree to terms when purchasing, that included having a safety professional conduct risk assessments, consult with employees and review their processes and documentation regularly.

Ideally every client who purchased a SWMS would follow our direction for implementation, however not all do. We see clients who haven’t conducted any risk assessments, who haven’t tailored the document to their worksite, or even consulted with their workers in relation to what the document contains. We openly advise potential clients that they are wasting their money, if the document isn’t implemented correctly.

Our SWMS are written by former Government Workplace Safety Inspectors, and we have only had five writers in the past seven years.

SafetyCulture’s mission now is to make safety available to every worker in the world. It is a basic human right, and currently the best systems are only available to those companies with large cheque books.

Our first prototype of a low cost, collaborative model was with the iAuditor application that we released in February 2012. It was based on the idea of allowing workers to share what they had created and then constantly improve it. I was not sure if the industry would embrace the technology yet, or if indeed companies were prepared to share what they create.

I think the trial has been a success. iAuditor is now used to conduct around 12,000 workplace inspections per day across the world. This number increases every week. Users have shared 5600 different types of audit forms. We have been contacted by many of the worlds largest companies to advise us, iAuditor has changed the way they manage safety audits. Users are able to export their audit data into their existing safety management systems for further action and analysis.

So, now we becoming focused on empowering workers with technology to work safer. iAuditor was simply a prototype, a test case if you like. From here we can build more features, such as followup actions and commence reporting and trend analysis to help us move closer to being able to identify risks and predict accidents ahead of time.

iAuditor also has met one other major requirement we had at the start of this project. It is free to use. This is very important, because it has changed the way companies test and identify their safety management systems. Due to costs and access restrictions, new safety management systems were only available to management staff, and only when and if management was ready, workers would then be exposed to the new idea or system.

But because iAuditor is free, we have seen workers download the app, start using it, test it, find the boundaries of it, and then suggest it to management for greater use. We are starting to see the beginning of a worker driven safety system, which has been the holy grail of every company I’ve worked with. Workers taking the initiative to work safer, to suggest changes, and to be willing to try new methods. This is a new paradigm of safety management.

We are actually working towards a model where SWMS can also be shared freely, and ultimately I hope that they are replaced with more engaging forms of training and compliance methods. Our team has been working on developing some of these more engaging methods of training and awareness. We have some announcements coming in 2013 in relation to how we are going to help this process.

As legislation is generally prepared in a reactive context, innovation and change is largely driven by private enterprise.

It may be surprising to also know that a significant part of our business comes from safety professionals who want to use a generic SWMS as a framework for delivering customised SWMS to their clients.

I would also respectfully suggest that the reference to Enron, Lehman Bros and Bernie Madoff is not appropriate. It’s a very long bow to draw and it attempts to paint us with some of history’s worst corporate villains. The team at SafetyCulture are focused on making safety available to all workers and we are committed to delivering low cost models of safety compliance that benefit all workers.

Luke, thanks very much for commenting. In terms of my discussion of the description “leading”. I don’t believe any reader would interpret any criticism of SafetyCulture. The term is used by SAI Global to describe your company. “Leading” is a common marketing term that I stated “describes market position and never product quality”.

It is heartening that the technical expertise for the development of the SWMS templates comes from “former Government Workplace Safety Inspectors”. That provides some comfort on the validity and relevance of the SWMS templates but my experience is that safety advice in high risk work, in particular, benefits greatly from a mix of literacy, knowledge and experience. Many companies name their experts and use their reputations as a selling point.

I have allowed your comment to be posted unedited but fail to see how iAuditor is relevant to a discussion of SWMS templates, SafetyCulture’s commercial relationship with SAI-Global or the matters raised in the ACT Construction industry report by Griggs and McCabe.

I wish you the best of luck with your company, the SAI-Global relationship is quite a coup.

This is all healthy discussion and as I said, I mostly agree with your comments in regards to the use of SWMS in the industry. I think your general tone also reflects the view of many professionals in the industry.

The reason I mentioned iAuditor, is to provide an example of how we need to move away from a paper based, sign away your responsibilities approach to safety.

The solution to this issue, I propose, is not going to come from further refinement of the paper systems we have in place, but rather, will come from a completely different method of working. The end goal is not to have signatures on a page, but rather to work safely. If the collective energy of safety professionals was directed towards innovation and solutions, we probably wouldn’t be here still talking about paper SWMS.

I felt that SafetyCulture was being tarred with a wide brush as a company that could be seen by people who hadn’t viewed our products as focused on making money, rather than helping people work safely.

In particular, your comment – “This has caused something of a stir with some Australian safety professionals who claim that this runs contrary to good safety practice” implies our products are not part of good safety practice.

iAuditor is the best example I have at the moment, that demonstrates that the SafetyCulture team is totally committed to actually helping thousands of people everyday work safer. It is the best example because it is free to use.

Much of the discussion around generic SWMS, their implementation and effectiveness is theoretical as there is very little data to measure the before and after performance of companies that purchase generic SWMS, particularly SME’s.

This data will start to flow as technology plays a greater role and is more affordable. We can then present data instead of opinions.

In regards, to our writers, our ideal writer would be someone with at least ten years trade experience, ten years legislative experience, and can write in a plain language format that a person with a year eight level of education can understand. Our writers usually have a bias towards either legislative or trade experience, and then proof each others work. Everyone has strengths in different areas, and we do our best to find the right balance.

Curiously, had you seen one of our SWMS at the time you made the post? If not, I’d be happy to send you one so you can see what they contain.

Luke, I think there is a major assumption that technology is an “answer” to safety inspections and auditing. When the cost of technology reduces and the useability increases, this is likely to be the case but most industries are many years away from that stage. Also, online technologies must be supported by backup and accessibility technologies that few companies have.

I think that a SWMS should only be developed after a Workplace Risk Assessment has been conducted on the Task. Only after the hazards are identified, risks assessed and controls decided can you develop a SWMS which has substance on the specific site. If you purchase generic SWMS then there is no substance behind it, No risk assessment. In a lot of cases the task being conducted is the same however the environment the task is being conducted in can introduce new or hidden hazards, if a risk assessment has not been conducted how will you identify these.

In my opinion, generic SWMS have substantial value. It will (and should) never replace a site assessment, involvement of workers, and consideration of task-specific factors. These are vital to include in an effective SWMS. A generic SWMS written by a safety professional can act to guide what is required in the legislation. This way, when a client purchases the SWMS they can make alterations to suit the task, the site, the equipment, the skill level and expertise of their workers, licenses/permits required, the time of day, local and State-specific requirements and any other hazards/risks as relevant. The purchased generic SWMS should only be used as a starting point to engender further discussion and assessment. Some clients have reported that, after purchasing a SWMS from SafetyCulture, they found new and better ways of doing the task that they had not thought of before. I see this as a positive thing.

I also want to take this opportunity to emphasize the message that a SWMS is task and site-specific. If you buy a generic SWMS from any company, make it your own. Talk to your workers, assess the job you are doing, make sure you have the skills, equipment and resources to do the job safely. Dont rely on a piece of paper. Develop procedures (a generic SWMS can help here in terms of meeting legislative requirements), inspect equipment, do the checks, use the controls you should be using and go home safely!

Yes Kevin, that is correct. I am speaking on behalf of myself with my comments above, however the great thing about SafetyCulture is that they do embrace best practice and new and innovative ways of making risk management more accessible to workplaces.

My first hand experience reveals that pre task created SWMS are not hitting the mark regarding on ground safety. That is they are created with the best of intentions to ensure conducting tasks safely. Unfortunately, the creators often dont have the knowledge to tease out all potential hazards in the upcoming task. When you think about how can you possibly list every potential situation. Recently, a workplace I was at showed me a list of 58 SWIs, 43 SOIs and 32 Forms. How could anyone fathom let alone someone on the tools.
Various consequences come into play as the tasks are impacted upon by the enviroment and unexpected hazards. Surely it can be seen that SWMS dont cover all bases.
On some SWMS there are options to provide further hazard or contron details at the end of the SWMS. My experience is that only one in one hundred actually add any further details.
As an organisation, we need to not only ensure people are safe but have evidence that they are acting safely.
At the same time a blank JSA is not the answer either.
So the trick is to create a system where the field scenarios dictate the documentation required to keep people safe. A system that is not tick and flick, but tick and goto works for me and my teams.